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27 SEPTEMBER 2000

IN REPLY,REFER TO:
L417-02-00-179

Federal Aviation Administration
Small Aircraft Directorate
901 Locust, Room 301
Kansas City MO 64106

 

ATTENTION:

Mr. Mike Kiesov
ACE-112

SUBJECT:

Fuel System Contamination Testing

REFERENCE:

1)

Cessna Letter L417-02-00-173 dated 14 September 2000, Subject:
Cessna/FAA Integral Tank Water Contamination Test Action Plan
 

2)

Cessna Letter L417-02-00-175 dated 21 September 2000, Subject:
Cessna/FAA Integral Tank Water Contamination Test Action Plan:
09/20/00 Meeting Synopsis
 

3)

Cessna Letter L417-02-00-176 dated 22 September 2000, Subject: Model
172R Integral Tank Water Contamination Investigation Test Plan-
Revision A

Dear Mr. Kiesov

On 13 September 2000, Cessna and the FAA met at Cessna's East Field Engineering Facilities to discuss
the content of Cessna's Fuel System Contamination Test, which will be used to conduct tank contamination
evaluation tests on the Model 172R. Cessna's letter of reference item 1 provided Cessna's understanding of
the agreements reached in that meeting. Per the agreements obtained, the Cessna/FAA team was tasked
with approving a finalized test plan by Friday, 22 September 2000. The following week, Cessna's Steve
Copeland and Doug Bassett met with the Wichita ACO's Jeff Janusz, Gerald Baker, and Jerry Brown to
accomplish a final coordination of the updated test plan. Several additional, substantial changes were
requested at this coordination meeting, as documented in the letter of reference item 2. This second set of
changes were immediately included in Revision A of the test plan, and provided to the FAA with the letter
of reference item 3 on the deadline date.

The FAA has reviewed Revision A of the test plan, and has provided Cessna with further requested
changes, included as an attachment to this letter. As stated in the message, the changes have been
coordinated, and have received concurrence both from the Wichita ACO and from the Small Airplane
Directorate. Cessna is concerned that with each iteration of review, the number of requested changes seems
to become more rather than less.

In light of the fact that agreement has not been reached on this issue and due to the issue's importance, and
due to the lack of progress toward agreement using other methods, Cessna proposes that the FAA and
Cessna convene another face-to-face meeting, similar to the one held on 13 September 2000, with only
necessary parties in attendance. The product of this meeting will be the establishment of a final agreement
with all necessary parties' approval of the finalized document, and with signed copies provided to each
participating group at the end of the meeting. Cessna furthermore proposes that this meeting be held at the
FAA's Small Aircraft Directorate Headquarters in Kansas City, or at a location chosen by the participants
themselves if their number is small enough.

Cessna will contact the Small Aircraft Directorate within the next week in order to establish a participants
list, a date and time for the proposed meeting. With the conviction that an agreement is best and most easily
reached using the fewest number of empowered, knowledgeable people as possible, Cessna will provide one
representative as necessary from Management, Project Group, Airworthiness, and/or Flight Test for the
meeting, and requests that the FAA similarly support the effort with as few empowered individuals as
possible. Cessna also would ask that the FAA provide a list of those individuals which it anticipates will
take part in the finalization activities. If the FAA determines that one individual may speak for all of the
FAA, Cessna will similarly appoint one person to address the issue on its behalf as well, and the process
will be much more efficient in reaching a timely resolution. Cessna will update the test plan document at
the finalization meeting, and will provide the electronic copy of the test plan for printout and signatures.

Cessna has been careful to communicate to the FAA that other business interests must be addressed, and
these projects must now be addressed immediately; therefore, Cessna will be unavailable for the proposed
meeting until the week of 16 October 2000; however, we believe this to be the only means of establishing a
finalized, agreed test plan.

Also included with this letter is a synopsis of Cessna's documented activity on the issue. As can be seen,
Cessna has worked diligently to establish suitable test guidelines with the FAA; however, to date no
agreement has been reached, and as stated, completion of other business issues has become critical. Cessna
believes that a timely resolution to the contamination testing issue continues to grow in importance by the
day, however.

Another attachment is also included which provides an update regarding Service Difficulty Report records
review. In the 13 September 2000 meeting, it was agreed that a search of both FAA and NTSB Service
Difficulty records would be conducted by the FAA, and Cessna would work with the FAA to review
those reports which had not already been addressed. The date for this item was agreed to be 27 September
2000; however, the schedule for the review now appears to be nebulous.

Due to the important nature of this issue, Cessna requests FAA concurrence with this proposal. Should the
FAA have questions or comments on the proposed actions, please do not hesitate to contact the
undersigned, at your convenience.

 

Very Truly Yours,
CESSNA AIRCRAFT COMPANY

 

Stan O'Brien
Cessna Single Engine Director of Engineering

 

cc: Dale Bleakney, Wichita ACO

 

L417-02-00-179

 

 

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